Linda Adelson

Linda advises on complex VAT issues across a range of sectors, including real estate, charities, retail, and financial services.

• Advising a number of gift voucher industry players on various complex issues concerning VAT and vouchers.
• Advised a charity on the VAT risks associated with their receipt of “grant” income in return for specified services and deliverables.
• Advising on the complex VAT risks of the purchase of an education business and subsequent corrective action for issues arising from poor VAT planning by the previous owner of the business.
• Acting for the developer of a student accommodation complex and advising on the VAT issues and risks arising from the scheme, including capital goods scheme risks and VAT recovery.
• Advising an LPA receiver on the VAT treatment of arrangements for the provision of receivership services, and their interaction with complex insolvency rules.

Linda advises financial insurance and fund management businesses on all relevant VAT issues, including on the availability of exemption, the VAT treatment of transfer pricing arrangements, VAT recovery issues, transactions and sales of assets, and the optimal structuring of arrangements, including VAT grouping.

• Advised an international insurance group on the VAT risks associated with its intermediary services being supplied alongside other taxable activities.
• Advised an international financial services group on the VAT risks associated with its transfer pricing arrangements, including on whether intercompany payments were consideration for supplies and if so, whether they were exempt.
• Managed a project to undertake a major review of a bank’s partial exemption methodology, and led negotiations with HMRC to get this agreed and to rebuild the HMRC relationship after resolving a legacy dispute on the method.
• Advising a large precious metals retailer on the VAT liability of its services and associated risks.
• Acted for a major insurance company on a variety of property issues arising from property investments in various forms (e.g. via SIPPS, within pension funds, JPUTs, and other funds).
• Collaborated with a Big 4 accountancy practice on a significant UK VAT reclaim for a major bank.
• Audited VAT processes within financial services businesses.

Linda advises on VAT disputes and supports litigation strategy, including developing technical arguments for tribunals and the courts.

• Acting in a successful appeal to the Upper Tribunal as to the VAT treatment of the sale of a banking platform to a well-known bank, and whether it should qualify as the transfer of a business as a going concern.
• Acting successfully in an important VAT case on the meaning of “consideration” for VAT purposes and whether VAT should be charged on amounts that are contractually restricted and not genuinely available to the supplier.
• Acted on numerous other complex appeals, for instance in a landmark case on the VAT treatment of fund management services.
• Acting for a well-known payment protection insurance claims company in litigation at the VAT Tribunal concerning the availability of VAT exemption for their services.
• Leading the response to HMRC on behalf of a major bank in relation to two major disputes and fact-finding exercises concerning the availability of VAT grouping and the VAT treatment of intercompany transfer charges.
• Successfully acting for a large outsourcing supplier in a business-critical and highly complex dispute with HMRC re whether their services were a single exempt supply, or included a separate taxable supply on which VAT was due.

Linda advises organisations in the financial services sector on VAT strategy, transactions, and risk issues.

• Advised major banks on VAT recovery and partial exemption issues.
• Advised fintech businesses on VAT implications of new products.
• Reviewed VAT risks of a consumer finance company of a car manufacturing group.
• Advised on VAT issues arising from intercompany services and transfer pricing arrangements.
• Advised on VAT treatment of precious metals transactions.
• Advised on VAT treatment of Islamic finance transaction.

Linda advises organisations in the insurance sector on VAT strategy, transactions, and risk issues.

• Advised an insurance broker on availability of exemption for intermediary services.
• Reviewed VAT risks of a complex international insurance group.
• Advised on VAT issues arising from intercompany services in an insurance group and transfer pricing arrangements.
• Advised a fund manager on VAT treatment of their services.
• Advised on the VAT treatment of insurance supplied alongside secure storage facilities.

Recognised by The Legal 500 as a Leading Individual for VAT

Recognised by Chambers UK for VAT

Linda Adelson “has ‘VAT in her DNA’ and significant in-house experience” – The Legal 500

“She is ‘a pure pleasure to work with’ because she is ‘extremely knowledgeable, resourceful and rigorous’.” – Chambers UK

Previous chair of VAT committee of the British Bankers Association